CITI for Aspen: which modules, keeping the certificate live, and what an expired one costs

CITI is not paperwork that trails the project. Aspen requires it completed before the application is submitted, names the certificates among the handful of attachments required on every application, and tells you to finish the training before drafting the consent form — which places it at the front of the sequence, not the end.

Charlotte Devereux, MSN, RN · filed 2026-08-23

In short. Aspen requires CITI training completed before the IRB application is submitted, with each module quiz passed at eighty per cent, and the certificates of completion uploaded with the application — one of only three attachments the checklist requires every time.

What is CITI, and what does Aspen require?

CITI is the Collaborative Institutional Training Initiative, and Aspen’s handbook describes it as training that helps researchers better protect the rights and welfare of human participants. The handbook frames the two as working together: it supplies the process, CITI supplies the substance, and the detail of how a board works is learned there rather than here.

The requirement itself is stated in one line on the What is CITI Training page: you must complete your CITI training prior to submitting your IRB application. Three practical details sit alongside it. The prompt to begin arrives in the appropriate course rather than by your own initiative. The training is described as lengthy, with time to be set aside for it. And each module carries a quiz that must be passed at eighty per cent — the handbook recommends taking notes, which is a small clue about how the material is assessed.

Then the instruction that turns training into a document: once complete, save the certificates, because they are uploaded with the application. The handbook suggests keeping an IRB folder from the outset so every attachment lives in one place — advice worth more than it looks, for the reason in the next section.

Why is the certificate one of the few things required every time?

Because Aspen’s application checklist is built in two tiers, and CITI sits in the upper one.

Appendix E’s two tiers, and where training sits
Tier	What it contains	What its absence means
Required with every application	The chair-approved application form, signed and dated; the university-approved proposal; your CITI certificates of completion.	The submission is incomplete, and Appendix E states plainly that an incomplete submission delays the work.
Required if applicable	Site permission, consent, assent, HIPAA authorisation, recruitment materials, other boards’ approvals, instruments and permissions to use them.	Absence is only a finding where the project’s design calls for the item — which the board reads from the application.

Everything in the lower tier is a judgement about your design; everything in the upper tier is unconditional. That matters when deciding what to chase first: a missing consent form may or may not be a problem, but a missing certificate always is, and it is the one gap needing no reading of the project to spot.

There is a second reason the timing is early. Aspen’s consent template opens by asking that CITI be completed before the consent form is drafted, because the training covers the material the form has to reflect — the elements, the voluntariness language, the way risk is described. Drafting first and training afterwards means writing the document twice.

Which modules should you expect?

The relevant family is CITI’s Human Subjects Research series, which is organised into two tracks — Biomedical, and Social-Behavioral-Educational. Each track offers a Foundations course covering the core topics and a Comprehensive course that adds advanced material, including extended treatment of informed consent, vulnerable populations, big-data work and mobile-app research. Refresher courses exist to retrain anybody whose basic course is already behind them, and the series carries role-specific and topic-specific courses besides, including one from the Office for Human Research Protections. All of the modules in the series reflect the 2018 requirements of the revised Common Rule.

The content of a Comprehensive course gives a fair picture of what the board assumes you now know. The social-behavioural version runs through the history and ethical principles that produced the regulations, the definition of research with human participants, the federal regulations and the criteria for exemption and expedited review, the assessment of risk, informed consent as both process and document, and privacy and confidentiality. Read that list beside Aspen’s handbook and the overlap is exact: it is the syllabus for every question the application asks.

Which track and which courses apply is not a matter to infer. Aspen’s handbook points to a short video that explains how to create an account and which courses to complete before submitting, and the current requirement lives in Aspen’s current handbook or IRB portal. Where the design is clinical — charts, patients, a unit — and where it is interview- or survey-based, the natural track differs, but the file follows the portal’s instruction rather than the logic.

How do you keep a certificate current?

By treating the completion report as a dated document rather than a permanent one.

CITI issues a completion report for each course, and that report carries its own validity period; the refresher exists precisely so training can be renewed rather than repeated from the start. What interval applies to your file is set by the course and by the institution’s own requirement, so the figure to work from is the one on your own report and in Aspen’s current handbook or IRB portal — not one borrowed from another institution’s guidance.

Two habits keep this from becoming a problem. Download the completion report as soon as it is issued, rather than relying on being able to reach the account later, and keep it in the same IRB folder as everything else the checklist asks for. And check the validity date against the project’s own horizon, not against today: work that will still be running when the report expires needs the refresher planned rather than discovered.

That second habit connects to the part of the process most people do not think about at submission. Approval is granted for a period, and where a project runs past it, Aspen’s Continuing Review Form is what carries it forward; the handbook is explicit that approval must be obtained to continue. Training that has quietly lapsed in the meantime is an awkward thing to discover at exactly that moment.

What does a lapsed or mismatched certificate actually do?

On its own, very little — and that is precisely why it is worth curing before anything else. A training gap is the cheapest finding in the catalogue: it costs an evening and a download. It becomes expensive only through company. A file that arrives with a stale certificate and a consent form that has drifted and a site letter that names the wrong activities is not read as three separate items; it is read as a file assembled without a final check, and the board’s attention adjusts accordingly.

Aspen says as much about neighbouring documents. Applications that are incomplete, that contain errors or typographical mistakes, or that provide inconsistent information will be delayed — and the handbook frames the application as telling the board a great deal about the person who assembled it. A certificate is the easiest possible signal to get right, which is what makes getting it wrong disproportionately loud.

Four versions of the same finding turn up repeatedly, and each has a one-line cure:

No certificate attached. The training was completed but never downloaded. Retrieve the completion report and attach it; nothing about the project changes.
The wrong artefact attached. A screenshot of a progress page rather than the completion report. Attach the report itself, with its identifiers and dates intact.
A certificate outside its validity period. Complete the refresher the course offers, then attach the new report.
The wrong course for the work. Check the requirement against Aspen’s current handbook or IRB portal and complete what it names, rather than assuming a course completed for another purpose transfers.

None of these is a reason to delay assembling the rest of the file. All of them are reasons to start the training on the day the project design settles, because it is the only item on the checklist whose completion depends on hours rather than on anyone’s decision.

Where does training sit in the sequence?

First, alongside the site permission request — and for the opposite reason. The letter is early because someone else controls its clock; the training is early because you control yours entirely, and because everything downstream reads better once it is done. The consent form drafted after CITI is a different document from the one drafted before it. So is the risk section of the application.

That ordering is the same one drawn on how it works: settle the design, settle the category, then build every document from a fixed plan. Training belongs to the settling, not the building. Questions that come up repeatedly at this stage are collected on the FAQ, and the attachment-by-attachment view has a piece of its own.

What to do next

Retrieve every completion report today, then check three things: that you have them as files rather than as an account you can log into, that the courses match what Aspen’s portal currently names, and that the validity dates outlast the project. If any of the three fails, fix it this week — it is the only finding in an IRB file that can be cured entirely on your own time. Then send the rest of the file for a reading, and find out what else a reviewer would mark.

The cheapest finding to cure is the one you fix before anyone else reads the file.

Request the free application review

Independent consultants, unaffiliated with Aspen University. The project and its findings stay yours; the determination is always the board’s. Also filed: the route from proposal to determination and the recruitment set, artefact by artefact.

Sources

Course requirements change. Confirm which modules apply against Aspen’s current handbook or IRB portal before you file.